Checklist of items a broker dealer needs to cover and how often

1. Rule Category As-Needed or when applicable Daily Weekly Monthly Quarterly Annually (*or rolling 12 months)
Heightened Supervision
Supervisory Control System FINRA rules 3012 (a) (1) Testing the
Supervisory Producing Manager Review Annual Review of Key Contacts
Designation of Principals – FINRA rules 3010(a)(2); 3010(b)(3) Firm's Written Supervisory Procedures to Ensure that All Rules are
System FINRA Rule 3012(a)(2))C) if – FINRA rule 1150
Addressed
App.
Supervisory Control System FINRA rules 3012 (a) (2) (i-iv) Identifying Review of Outsourcing
Annual Compliance and Supervision Certification – FINRA rule
Producing Managers and Assigning Qualified Supervisors FINRA Rule Activities to Third-Party Service
3013(b)
3012(a)(2))C) Providers – FINRA rule 3010
Supervisory Control System FINRA rules 3012 (b) (2) (i) (ii) Supervision
Review of Businesses – FINRA rule 3010©
of Transmittal of Customer Funds or Securities
Supervisory Control System FINRA Rule 3012(a)(2)(B) Supervision of
Annual Compliance Meeting or Interview – FINRA rule 3010(a)(7)
Customer Changes of Address -
Supervisory Control System FINRA Rule 3012(a)(2)(B) Supervision of
Form BD and Membership Agreement – FINRA By-Laws Art. IV,
Customer Changes of Investment Objective -
Section 1
Supervisory Control System FINRA Rule 3012(a)(2)(A)(ii) Use of the
Limited Size and Resources Exception for Branch Manager Supervision, Annual Review of Key Contacts – FINRA rule 1150
Including the Factors Used in Determining the Exception is Necessary -
Heightened Supervision Procedures -FINRA Rule 3012 (a)(2)C)
Designation of Chief Compliance Officer –FINRA rule 3013(a)
Designation of Contact Persons – FINRA rule 1150
Determining Qualifications of Supervisory Personnel – FINRA rule
3010(a)(6)
Designation of Principal Responsible for Supervision of Form Filings –
FINRA rule 1140
Assignment of Registered Persons – FINRA rule 3010(a)(5)
Supervisory Personnel Record including titles, registration status and
locations – SEC rule 17a-3(a)(12)
Distribution of Procedures and Amendments – FINRA rule 3010(b)(4)

2. Rule Category As-Needed or when applicable Daily Weekly Monthly Quarterly Annually (*or rolling 12 months)
Form BD and Membership Agreement – FINRA By-Laws Art. IV, Section
1
Designation of Persons Responsible for Explanation of Books and
Records– SEC rules 17a-3 and 17a-4 & FINRA rule 3110
Records of Reports - Records of Procedures and Manuals
Soft Dollars – SEC Section 28(e)
Approval of Outsourcing Activities to Third-Party Service Providers –
FINRA rule 3010
Compliance Announcements of Rule Updates
SRO Inquiries
Branch Office Inspection Schedule for Locations at which the Firm Conducts
Locations at which the Firm Conducts Business – FINRA rule 3010(c)(1)
Activities Business – FINRA rule 3010(c)(1)
Rules Applicable to Supervision of Non-OSJ Branch Office Activities -
Annual OSJ Inspection – FINRA rule 3010 ©
FINRA rule 3010 ©
Periodic Review of Non-Branch Location - FINRA rule 3010 © Branch Office Inspection - FINRA rule 3010 ©
Supervision of Non-Branch Business Locations - FINRA rule 3010 ©
Broker-Dealer Activity on Premises of Financial Institutions – FINRA rule
2350
Ongoing Personnel Registration
Personnel Proper registration and Disclosures to New Hires/Terminations, Periodic Outside Business Activities - Initial and Annual Attestation – FINRA
– Periodic Review – FINRA rule
Matters reviews exam scheduling coordination etc. – FINRA rule 3080 rule 3030
1120
Organization Chart Update Private Securities Transactions - Initial and Annual Attestation –
Fingerprinting – SEC rule 17f-2 and FINRA rule 1140
Review FINRA rule 3040

3. Rule Category As-Needed or when applicable Daily Weekly Monthly Quarterly Annually (*or rolling 12 months)
Continuing Education – Needs Analysis Assessment – FINRA rule
Monitor compliance with
Background Investigations – FINRA rules 3010(a)(6) and 3010(e) 1120
regulatory element 1120
Proper Registration Upon Hire - FINRA By-Laws, Article III, Section 2; Continuing Education – Training Plan and Materials - FINRA rule
FINRA rules 1070; 1021; 1022; 1030; 1040; 1100; & 1110 1120
Continuing Education – Maintain records of attendance - FINRA rule
Ongoing Personnel Registration – Changes in Duties – FINRA rule 1120
1120
Personnel Files Identification Numbers or Codes Continuing Education – Designate CE contact with FINRA
Parking of Securities Registrations – FINRA rule 1031(a)
Supervision of Statutorily Disqualified Individuals – FINRA By-Laws,
Article III, Sections 3 and 4; FINRA rule 3070
Termination of Registration - FINRA By-Laws, Article III, Sections 3 and 4
Continuing Education – Regulatory Element – FINRA rule 1120
Outside Business Activities - Initial Request – FINRA rule 3030
Outside Business Activities - Initial and Annual Attestation – FINRA rule
3030
Private Securities Transactions - Requests & records of – FINRA rule
3040
Compensation Arrangements and Employee Agreements Compensable
Transactions
Customer Complaints – FINRA rule 3110
Reporting of complaints, actions etc. – FINRA rule 3070

4. Rule Category As-Needed or when applicable Daily Weekly Monthly Quarterly Annually (*or rolling 12 months)
Trading in Advance of
Insider Trading Restricted Lists Chinese Walls Insider Trading Training
Research – FINRA IM 2110-4
Monitoring for Insider Trading, update employees on new rules for insider Restricted List -Compliance Front Running – FINRA IM-
Insider Trading Require employee to sign attestation NTM-91-45
trading Review 2110-3
Net Capital Computation (Trial
Financial Net Capital - Part I - SEC rules Net Capital - Part II - SEC rules
FinOp Training – NTM 06-23, 1022(b); 1022©, Balance) – SEC rules 15c3-1 FinOp Assessments – NTM 06-23
Reporting 15c3-1 and 17a-11 15c3-1 and 17a-11
and 17a-11
FinOp Periodic Reviews (NTM
FinOp Periodic Reviews – NTM 06-23 Audited Financials - SEC rules 17a-5 and 17a-11
06-23)
Charges for services performed-
On-Site Documentation – NTM 06-23
FINRA rule 2430
Net Capital - Early Warning - SEC rules 15c3-1 and 17a-11
Material Inadequacy - SEC rule 17a-5(g)(3)
Designation of Accountant - SEC rule 17a-5(f)(4)
Customer Reserve – SEC rule 15c3-3
Handling Customer Funds and Securities - SEC rules 17a-5 and 17a-11
Lost and Stolen Securities - SEC rules 17a-5 and 17a-11
Margin Requirements – FINRA rule 2520 Cash Account Provisions of
Reg.-T
FINRA Fees and Assessments- FINRA By-Laws Schedule A
Charges for services performed – FINRA rule 2430

5. Rule Category As-Needed or when applicable Daily Weekly Monthly Quarterly Annually (*or rolling 12 months)
Mandatory Electronic Filings – FINRA rule 3170
Customer Exception Reports (Pershing) Prohibition Against Guarantees - Changes of Customer Address Customer Account Statements
Acceptance of New Accounts – Customer Approval SIPC Disclosure
Accounts FINRA 3230© NTM 99-57 FINRA rule 2330(e) FINRA Rule 3012(a)(2)(B) (2340)
Spot Check Clock Changes of Customer
Markups and Commissions -
Acceptance of New Accounts - Imposition of Credit Limits Synchronization - FINRA rule Investment Objectives FINRA Investor Education & Protection 2280
FINRA IM-2430, 2440
6953 Rule 3012(a)(2)(B)
Accounts for Persons Associated at Other Broker/Dealers – FINRA rule Transaction Monitoring, Trade reporting by 3rd parties if FINRA Compliance Report
3050 Account Reviews applicable Cards
Trade Reporting
Periodic Review of Open
Furnishing Account Information to Customers ACT/OATS/TRACE Reporting
Accounts 3010(d)
FINRA rule 6130
Records of Customer Agreements General Fails & DKs Account Activity - review
Borrowing From or Lending to Customers – FINRA rule 2370
Account Designation Changes – FINRA rule 3110(j)
Changes of Address- FINRA rule 3110(j)
Mail - FINRA rule 3110(i)
Churning – FINRA IM-2310-2
Customer Account Statements & Order Tickets– FINRA rule 2110, 10b-
10, 11Ac-3,2320,2830,3110, SEC Rule 17a-3(a)
Risk Management (financial or credit account level or credit breaches)
Dealing with Ongoing Personnel Registration
Daily Review of Accounts - Unauthorized Trading – FINRA Gifts and Gratuities – Approval
Customers and Suitability of Recommendations – FINRA rule 2310 – Periodic Review – FINRA rule Employee and Related Accounts - FINRA rule 2110
FINRA rule 3010© IM-2310-2 Process - FINRA rule 3060
Activities of RR's 1120

6. Rule Category As-Needed or when applicable Daily Weekly Monthly Quarterly Annually (*or rolling 12 months)
Reg SP Privacy and Opt-out notifications, including procedures for
Employee and Related FINRA Contact Information
Markups and Commissions - FINRA IM-2440 ensuring customer information is safeguarded, ensure proper
Accounts - FINRA rule 2110 review FINRA rule 1150
disposal of consumer report information
Approval of Account Name or Designation Changes for Orders - FINRA Trading in Advance of Registration of Research Analysts FINRA 1050, 2711, NTM 07-04,
Continuing Education Updates
rule 3110 Research (FINRA 2110) NTM 0481, NTM 04-18
Prohibition Against Guarantees - FINRA rule 2330(e) Research Quit Periods FINRA 2711, 2210
Gifts and Gratuities – Aggregation of Gifts - FINRA rule 3060
Gifts and Gratuities – Business Entertainment
Accounts Maintained at Other Broker-Dealers - List of Personal Accounts
at Time of Hire – FINRA rule 3050
Accounts Maintained at Other Broker-Dealers - Receipt of Statements
and Confirms – FINRA rule 3050
Employee and Related Accounts - FINRA rule 2110
Reg SP Privacy and Opt-out notifications, including procedures for
ensuring customer information is safeguarded, ensure proper disposal of
consumer report information
U-4/U-5 or Form BD Disclosures or Updates
Outgoing Written Outgoing Electronic
Communication Advertising & Sales Literature - (including e-mail & websites) FINRA rule
Communication - FINRA rule Communication - FINRA rule
with the Public 2210
3010(d) 3010(d)
Incoming Written Incoming Electronic
Institutional Sales Literature & correspondence - FINRA rule 2211 Communications - FINRA rule Communications - FINRA rule
3010(d) 3010(d)
Instant Messaging (Bloomberg) -
Speaking Engagements, scripts, outlines - FINRA rule 2210
FINRA rule 3010(d)
quot;Internal Use Onlyquot; Material not released to Public

7. Rule Category As-Needed or when applicable Daily Weekly Monthly Quarterly Annually (*or rolling 12 months)
Cold-Calling - FINRA rule 2210
Payment for Order Flow - FINRA rule 2110
Fixed Income Securities
Trade reporting –
Best Execution - FINRA rule Clock Synchronization - FINRA
Trade Reporting Securities Parking Review – FINRA rule 2110 ACT/OATS/TRACE FINRA
2320 rule 6953
Rule 6130
Timely Acceptance and Entry of
Adjusted Trading: Trade Errors, Commission Adjustments & Position Comparison of OATS and ACT
Trades Reportable by Other
Logs Data – FINRA rule 6954
Firms – FINRA rule 6130
Correctly Marking and reporting
a Sale as Long, Short, or Short
Best Execution – Routed Orders – FINRA rule 2320
Exempt – SEC rule 203, FINRA
rule 6130
OATS Data Accuracy -
Monitoring the Accuracy and
Interpositioning – FINRA rule 2320 Timeliness of OATS
Submissions by Third Parties -
FINRA rule 6954
Correction and Re-submission
Trade reporting – FINRA rule 6130 of Data Rejected by OATS –
FINRA rule 6954
Riskless Principal Trade Reporting – FINRA rule 6130
Anti-Competitive Practices – SEC 21(a) Report and FINRA IM-2110-5
Transmitting OSO Agreement - FINRA rule 6954
OATS Announcements of Updates from FINRA.ORG
Handling of Customer Orders During Market-Wide Trading Halts
Records of Executions

8. Rule Category As-Needed or when applicable Daily Weekly Monthly Quarterly Annually (*or rolling 12 months)
Business Emergency Contact Persons, Significant Business Disruptions (quot;SBDquot;), Daily Data Backup (Hard & Weekly Data Backup (Hard & Monthly Data Back-Up Quarterly Data Back-Up
Approval and Execution Authority
Continuity Plan Location and Access, Clearing Firm Electronic Systems) Electronic) (Electronic) (Electronic)
Office Location(s), Alternative Location (s) Updates and Annual Review
Customer' Access to Funds and Securities
Data Back-Up (Hard Copy)
Data Back-Up and Recovery (Hard Copy and Electronic)
Operational Risk
Financial and Credit Risk
Mission Critical Systems
Clearing Firm Responsibilities
Recovery Time
Order Taking
Order Entry
Order Execution
Alternative Communications – Customers

9. Rule Category As-Needed or when applicable Daily Weekly Monthly Quarterly Annually (*or rolling 12 months)
Alternative Communications – Employees
Business Constituents-Banks
Counter-Parties
Regulatory Reporting
Disclosure Statement
Providing AML Information to
federal Law Enforcement
Anti-Money
AML Procedures - Amendments 3011 Agencies and Other Financial Wired Funds/Securities (AML) AML Compliance Program - Approval 3011
Laundering Institutions - FinCEN Requests
Under PATRIOT Act Section
*all elements required FinCEN Requests Under
AML Procedures - List of Entities Covered Restricted by FinCEN Special
even if considered PATRIOT Act & Bank Secrecy Annual Audit Independent Test 3011
quot;NAquot; to business
Measures
Act Section 314 bi-weekly
Firm’s AML Policy Senior Manager Approval of AML Program
AML – AML Compliance Officer Designation and Duties AML-Contact Person
Providing AML Information to federal Law Enforcement Agencies and
Other Financial Institutions - Sharing Information With Other Financial
Institutions US Patriot Act, Section 314
Checking the Office of Foreign Assets Control (“OFAC”) List
Customer Identification and Verification -Required Customer Information
NTM 03-34
Customer Identification and Verification - Customers Who Refuse To
Provide Information
Customer Identification and Verification - Verifying Information

10. Rule Category As-Needed or when applicable Daily Weekly Monthly Quarterly Annually (*or rolling 12 months)
Customer Identification and Verification - Lack of Verification
Customer Identification and Verification - Comparison with Government
Provided Lists of Terrorists and Other Criminals
Customer Identification and Verification - Notice to Customers
Customer Identification and Verification - Reliance on Another Financial
Institution for Identity Verification
Foreign Correspondent Accounts and Shell Banks - Detecting and
Closing Correspondent Accounts of Foreign Banks and Shell Banks
Private Banking Accounts/Foreign Officials
Transaction Monitoring, Account Reviews
SAR Filing - Responding to Red Flags and Suspicious Activity
Currency Reporting and Wire Transfers - Generally
Currency Reporting and Wire Transfers - Currency Transaction Reports
Currency Reporting and Wire Transfers - Currency and Monetary
Instrument Transportation Reports
Currency Reporting and Wire Transfers
Foreign Bank and Financial Accounts Reports (“FBAR”)
Filing currency transaction reports CTR's Bank Secrecy Act

11. Rule Category As-Needed or when applicable Daily Weekly Monthly Quarterly Annually (*or rolling 12 months)
Ongoing Training
Confidential Reporting of AML Non-Compliance
Monitoring Employee Conduct and Accounts
Senior Manager Approval of AML Program

12. Rule Category As-Needed or when applicable Daily Weekly Monthly Quarterly Annually (*or rolling 12 months)